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CSA CONSULTATION PAPER 92-401 Derivatives Trading Facilities (the “Proposed Amendments”)
Letter Summary:
It is appropriate to permit a DTF operator a degree of discretion over the execution of transactions because it provides additional flexibility for clients. Discretion should be permitted for trading in some products that are mandated to trade on a DTF, such as
semi-standard swaps (e.g. CDS, IRS).
Overview of the Council’s Comments:
The Canadian Advocacy Council for Canadian CFA Institute Societies (the CAC) appreciates the opportunity to comment on and wishes to provide comments on the following specific questions posed with respect to the Proposed Amendments.